Equal Employment Opportunity Employer (EEOE) Policy

Effective Date: January 1, 2025

Last Updated: December 21, 2025

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Rivvia Sales is committed to providing equal opportunities in all aspects of our operations, including the recruitment, engagement, and management of independent contractors, without regard to protected characteristics. We comply with all applicable federal, state, and local laws prohibiting discrimination, including those enforced by the U.S. Equal Employment Opportunity Commission (EEOC). Specifically, we adhere to:

• Title VII of the Civil Rights Act of 1964 (prohibiting discrimination based on race, color, religion, sex, or national origin).

• The Americans with Disabilities Act (ADA) of 1990, as amended (prohibiting discrimination based on disability and requiring reasonable accommodations).

• The Age Discrimination in Employment Act (ADEA) of 1967 (prohibiting discrimination against individuals 40 years of age or older).

• The Genetic Information Nondiscrimination Act (GINA) of 2008 (prohibiting discrimination based on genetic information).

• The Equal Pay Act (EPA) of 1963 (requiring equal pay for equal work regardless of sex).

• Executive Order 11246 and related regulations (prohibiting discrimination in federal contracting based on race, color, religion, sex, sexual orientation, gender identity, or national origin).

• State-specific laws, such as the California Fair Employment and Housing Act (FEHA), New York State Human Rights Law (NYSHRL), and others where applicable.

 

This policy applies to all individuals interacting with Rivvia Sales, including applicants, independent contractors, vendors, and partners. No employment relationship is created through contractor engagements; however, we extend these protections to ensure fair treatment in all business dealings.

Protected Characteristics Discrimination, harassment, or retaliation is strictly prohibited based on the following characteristics:

• Race (including traits historically associated with race, such as hair texture, hairstyles, or protective styles).

• Color.

• Religion or religious creed (including religious dress, grooming practices, beliefs, observances, and practices).

• Sex (including pregnancy, childbirth, breastfeeding, or related medical conditions).

• Gender, gender identity, gender expression, or sexual orientation.

• National origin, ancestry, or citizenship.

• Age (40 years and older under the ADEA).

• Physical or mental disability, medical condition (including cancer, genetic conditions, or reproductive health decision-making), or genetic information.

• Marital status, domestic partnership, or family status.

• Veteran or military status.

• Political affiliation.

• Any other characteristic protected by federal, state, or local law.

 

This includes actual possession of the characteristic, perception of possession, or association with someone who has or is perceived to have the characteristic.

Covered Practices This policy governs all aspects of our operations, including but not limited to:

• Recruitment and advertising for contractor opportunities.

• Application review, interviews, and selection.

• Onboarding, training, and provision of resources or tools.

• Assignment of territories, leads, or sales opportunities.

• Performance evaluations, commission payments, and incentives.

• Access to support, mentorship, or professional development.

• Disengagement or termination of contractor agreements.

• Interactions with partners (e.g., AT&T, T-Mobile) and compliance with their guidelines.

 

All decisions are made based solely on merit, including qualifications, skills, experience, performance, availability, professionalism, adherence to role requirements, and compliance with laws and policies. No quotas, diversity targets, or preferential treatment based on protected characteristics are used.

Prohibition of Discrimination Discrimination means any unequal or adverse treatment in the above practices based solely or in part on a protected characteristic. Examples include: denying opportunities due to age, refusing accommodations for religious practices, or basing commission assignments on perceived disability.

Prohibition of Harassment Harassment is any unwelcome verbal, visual, or physical conduct based on a protected characteristic that creates an intimidating, hostile, or offensive environment or interferes with performance. Examples include:

• Verbal: Slurs, jokes, epithets, derogatory comments, or threats.

• Visual: Offensive posters, images, emails, or gestures (e.g., leering, staring).

• Physical: Unwanted touching, blocking movement, or assault. Sexual harassment includes unwelcome advances, requests for favors, or other conduct of a sexual nature, whether quid pro quo (e.g., linking opportunities to submission) or creating a hostile environment.

 

Prohibition of Retaliation Retaliation is prohibited against anyone engaging in protected activities, such as:

• Reporting or opposing discrimination or harassment.

• Participating in an investigation or complaint process.

• Requesting a reasonable accommodation.

• Filing a charge with the EEOC or a state agency. Adverse actions include suspension of opportunities, reduced commissions, negative evaluations, or harassment. Even subtle actions that deter protected activities are prohibited.

 

Reasonable Accommodations We provide reasonable accommodations for disabilities (under the ADA), religious beliefs/practices, or pregnancy-related conditions, unless doing so causes undue hardship. Requests should be made in writing to the Compliance Officer; we will engage in an interactive process to assess and implement accommodations promptly (within 10 business days of request, where feasible).

Reporting Procedures If you experience or witness a violation:

1. Immediately inform the offender to stop (if safe).

2. Report to your primary contact, supervisor equivalent, or the Compliance Officer at compliance@rivviasales.com.

3. Use the anonymous reporting form on our website or via email. No formal chain of command is required. Reports can be verbal or written and will be documented.

 

Investigation and Resolution All reports are investigated promptly (initiated within 48 hours), fairly, and confidentially by qualified personnel (e.g., HR or external investigators). The process includes:

• Interviewing parties and witnesses.

• Reviewing evidence.

• Completing the investigation within 30 days (extensions only if necessary, with notice).

• Taking corrective action if substantiated, such as training, suspension, termination of agreement, or referral to authorities.

• Notifying the complainant of outcomes (to the extent permissible). Cooperation is required; failure to cooperate may result in disciplinary action.

 

Training and Enforcement All contractors receive training on this policy during onboarding and annually. Violations may lead to immediate disengagement, forfeiture of commissions, or legal reporting. We conduct periodic audits to ensure compliance.

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Non-Discrimination Policy

​​Effective Date: January 1, 2025
Company: Rivvia Sales

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1. Policy Statement

Rivvia Sales is committed to operating in a fair, lawful, and merit-based manner. All recruiting, contracting, training, compensation, territory assignment, and operational decisions are made without discrimination or preferential treatment of any kind. Rivvia Sales does not use hiring quotas, diversity targets, or outcome-based selection criteria. All decisions are based solely on qualifications, performance, availability, business needs, professionalism, and compliance with applicable laws and company policies.

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2. Scope of Policy

This policy applies to all aspects of Rivvia Sales operations, including but not limited to:

• Recruiting, advertising, and application review

• Independent contractor engagement and onboarding

• Training, mentorship, and access to resources

• Territory assignments and sales opportunities

• Performance evaluation and advancement

• Commission eligibility and payment

• Suspension, disengagement, or termination

• Access to internal systems, tools, and support

This policy applies to all applicants, independent contractors, representatives, partners, and internal personnel.

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3. Equal Treatment and Prohibited Discrimination

Rivvia Sales does not discriminate against any individual based on characteristics unrelated to lawful business requirements or performance.

Prohibited discrimination includes, but is not limited to, actions based on:

• Race or ethnicity

• Color

• Religion or creed

• Sex

• Sexual orientation

• Gender identity or gender expression

• Age (where legally protected)

• Disability or medical condition (where legally protected)

• Veteran or military status

• Education level

• Socioeconomic status or class

• Marital or family status

• Any other characteristic protected by applicable federal, state, or local law

 

4. No Quotas or Preferential Treatment

Rivvia Sales expressly prohibits:

• Hiring or contracting quotas

• Diversity targets or benchmarks

• Preferential or adverse treatment based on personal characteristics

No individual is favored or disadvantaged for reasons unrelated to merit, performance, availability, or lawful business needs.

 

5. Merit-Based Decision Framework

All decisions are made using objective, lawful criteria, including:

• Availability in active fiber or sales markets

• Ability to meet role requirements and compliance standards

• Communication skills and professionalism

• Completion of required training

• Sales performance and customer conduct

• Adherence to partner, regulatory, and company requirements

 

6. Independent Contractor Status

Many Rivvia Sales representatives operate as independent contractors. Nothing in this policy creates an employment relationship or alters contractor classification.

Independent contractors retain control over their work methods, subject to compliance with Rivvia Sales policies, partner requirements, and applicable law.

 

7. Harassment and Retaliation

Harassment, intimidation, or retaliation based on any protected or personal characteristic is strictly prohibited.

No individual will be retaliated against for:

• Raising a good-faith concern

• Reporting suspected discrimination or misconduct

• Participating in an investigation or review

 

8. Reporting Concerns

Concerns may be reported through Rivvia Sales support or compliance channels. Reports will be reviewed promptly and objectively, with confidentiality maintained where reasonably possible.

Knowingly false or malicious complaints may result in corrective action.

 

9. State and Local Law Compliance

Rivvia Sales complies with all applicable federal, state, and local non-discrimination laws in every jurisdiction where it operates.

 

This includes, where applicable, laws such as:

• California Fair Employment and Housing Act (FEHA)

• New York State Human Rights Law (NYSHRL)

• Maine Human Rights Act

• Texas Labor Code

• Applicable Florida and municipal ordinances

 

Where state or local law mandates additional protected classifications, notice requirements, or procedural obligations, Rivvia Sales will comply fully. Compliance with state or local law does not create quotas, preferences, guarantees, or outcome-based selection requirements and does not override Rivvia Sales’ merit-based framework. If any provision of this policy conflicts with applicable law, the law will govern to the minimum extent required, and the remainder of this policy will remain in full force and effect.

 

10. Enforcement and Violations

Violations of this policy may result in corrective action, including but not limited to:

• Mandatory retraining

• Suspension or restriction of system or territory access

• Termination of the contractor relationship

• Forfeiture of commissions where legally permitted

• Reporting to partner providers or regulatory authorities when required

 

11. Policy Updates

Rivvia Sales reserves the right to update or modify this policy at any time to reflect changes in law, regulatory guidance, or business operations. The most current version published on the website shall govern.

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